CARDIONET, LLC v. INFOBIONIC, INC.

CARDIONET, LLC v. INFOBIONIC, INC., Appeal No. 2019-1149 (Fed. Cir. April 17, 2020).  Before Dyk, Plager and Stoll.  Appealed from D. Mass. (Judge Talwani).  (Patent Eligibility)

Background:

CardioNet sued InfoBionic for infringement of its patent directed to a cardiac monitoring system for detecting and distinguishing atrial fibrillation and atrial flutter from other types of cardiac arrhythmia.  The claimed system requires the use of conventional technology to detect and measure electrical signals of the heart, and the measured signals are used to determine variations in the beat-to-beat timing of the patient’s heart rate.  In particular, the system analyzes an electrocardiogram to determine variations between R to R intervals formed between ventricular contractions (i.e., QRS complexes 215, 220, 225 in Fig. 2).  In this way, the system determines whether a patient is experiencing atrial variations, and then issues an alert to staff when atrial variations are determined to occur.

InfoBionic filed a motion to dismiss for failure to state claim, alleging that the patent was directed to patent-ineligible subject matter under 35 U.S.C. § 101.  The district court agreed with InfoBionic and dismissed the case, finding that the claims were directed to an abstract idea, and thus, did not constitute patent-eligible subject matter.

Issue/Holding:

Did the district court err in finding that the claims were not directed to patent-eligible subject matter?  (continue reading)

Summary byDonna Mason

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